3 July 2011
The Chair and Members of the CDM Executive Board
c/o the UNFCCC Secretariat
P.O. Box 260124
D-53153 Bonn
Germany
Dear Sir/Madam,
Re: Call for Public Inputs on Sustainability Benefits
The Institute for Global Environmental Strategies (IGES)1 Climate Change Group and Market Mechanism
Group2 welcomes the clean development mechanism (CDM) executive board’s (EB) call for public inputs on
how to include co-benefits and negative impacts in the documentation of CDM project activities and the role
of the different actors and stakeholders in this process.
In responding to the call, we would like to submit our proposals on how co-benefits can be better
recognized within the current system. Our proposals outlined below aim to raise the visibility of co-benefits in
the CDM. We highly appreciate if our inputs would be considered during the preparation of an information
note by the secretariat and taken into account by the Board in future meetings.
1. Revision of PDD Guidelines to better reflect the co-benefit effect from the proposed CDM project
activity
The CDM-PDD is the most essential document that all the stakeholders (e.g. project participants (PPs),
designated operation entity (DOE), designated national authority (DNA) and general public), involved during
the CDM project cycle will refer to.
For PPs, the CDM-PDD is the only document that they can describe
how the proposed project could deliver co-benefits. Therefore, it is important that the CDM-PDD should be
designed so as to provide opportunity for PPs to describe the co-benefits while not increasing the transaction
costs.
In the current PDD format3, PPs can describe the contribution to sustainable development of host country in
the section A.2. “Description of the (small-scale) project activity.” Accordingly, the guidelines for completing
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IGES is serving as the Secretariat of the Asian Co-benefits Partnership (ACP), an informal and interactive platform designed to improve information
sharing and stakeholder communication on co-benefits in Asia. The ACP and its partners have conducted a significant amount of work on co-benefits.
2
IGES Market Mechanism Group has been implementing capacity building activity for promoting market mechanisms including
CDM with funding from the Ministry of the Environment Japan.
3
CDM-PDD (Project Design Document form) version 3 and CDM-SSC-PDD (Project Design Document form for
Small-Scale project activities) version 3
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the CDM-PDD4 provide guidance as to how the section to be filled (Quoted from page 6 of the guidelines):
In our view, the guidance should be revised as follows to specifically recognize the co-benefits from the
proposed CDM project activity.
Proposed revision in the PDD Guideline Ver.7 (Bold with underline indicates the revision)
A.2. Description of the project activity (Page 6)
(1) The purpose of the project activity with a concise description (a couple of paragraphs) of:
(a) The scenario existing prior to the start of the implementation of the project activity;
(b) The project scenario, including a summary of the scope of activities/measures that are being
implemented within the proposed project activity;
(c) The baseline scenario, as identified in section “B.4 Description of how the baseline scenario is identified
and description of the identified baseline scenario”.
If the baseline scenario is the same as the scenario existing prior to the start of implementation of the
project activity, there is no need to repeat the description of the scenarios, but only to state that both are the
same. In the purpose of the project activity, co-benefits effect, if any, might/could preferably be taken
into consideration.
(2)
(3) The view of the project participants on the contribution of the project activity to sustainable development,
especially through co-benefits effects (max. one page)
A.4.3. Technology to be employed by the project activity: (Page 8-9)
The description of the scenarios may include, inter alia:
(a)
(b)
(c)
(d) The co-benefit effects through technological improvement as expressed in terms of its effect in some
indicators (e.g. SOX, NOX, PM, among many others).
For the quantification of co-benefit effects from the CDM project activity, the “Manual for Quantitative
Evaluation of the Co-Benefits Approach to Climate Change Projects” compiled by the Ministry of the
Environment
of
Japan
could
provide
as
an
example
in
this
approach
(http://www.env.go.jp/en/earth/cc/manual_qecba.pdf).
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“Guidelines for Completing the Project Design Document (CDM-PDD) and the Proposed New Baseline and
Monitoring Methodologies (CDM-NM)” version 7
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It should be noted that the description and the mentioning of the co-benefit effects in the PDD should be a
voluntary in nature in order not to increase the transaction cost in the CDM cycle.
However, the description
of co-benefits in the PDD will convey more information than the current one as to how and how much the
project contributed in addition to the mitigation of GHGs (greenhouse gases).
Is should also be emphasized that the effective implementation of the revised PDD guidelines will require
the development of sophisticated evaluation tool coupled with capacity building activities for the stakeholders
involved.
The following sections describe the example of such tools and suggestions on the capacity
building initiatives.
2. Development and Dissemination of Co-benefits Evaluation Tool
Co-benefits enhance the overall desirability of CDM project activity. Some projects have huge local
co-benefits—as is the case of the transportation sector—that could generate support from host country and
strengthen implementation.
However, recognition of co-benefits has been patchy and sporadic, partly
because there is limited capacity to quantify co-benefits and “measurable impacts” often draw more attention.
We therefore propose that tools to quantify co-benefits be made available to project developers, DNAs and
DOEs.
Common metrics on how to quantify co-benefits will facilitate comparability among different CDM
projects. Some organizations have started work on this and may share their resources. IGES, for example, has
developed a guide to quantify transport co-benefits with spreadsheet based calculator to quantify air pollutants
other than CO2 (PM and NOx), benefits from time savings, vehicle operating costs savings, and traffic safety
(see Figure 1). Other tools could be tailored to the needs of other sectors.
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Figure 1: Excel based co-benefits calculator for transport projects
3. Capacity Building Activity on Co-benefit CDM
3.1 Build Capacity through the DNA Forum
As suggested previously, a lack of capacity is a significant barrier to integrating co-benefits into the CDM.
The DNA Forum offers a potentially important arena to build the needed capacity. We therefore propose that
the DNA forum may host voluntary training programs for quantifying the co-benefits of CDM projects. Many
co-benefits—such as reductions in air pollution and improvements in public health—can be estimated with the
data gathered for measuring GHGs. And many countries have already developed good schemes for looking at
a project activity’s sustainable development contribution. These proven techniques and lesson learned can be
shared through the training program. The program could also emphasize south-south cooperation and support
data compilation for analytical inputs that are more likely to be comparable in developing country contexts.
3.2 Launch a Co-benefits Showcase
Many CDM projects generate significant co-benefits but awareness of their sustainable development
contribution remains low. The EB could help raise the profile of exemplary projects by creating a “co-benefits
showcase.” The showcase would be located on the UNFCCC CDM website and would include inter alia an
overview of the project, a guide to quantifying the project’s co-benefits, and potential options for scaling up
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the project. A modest financial reward for being selected for the showcase would encourage project
developers and the DNA to nominate projects for consideration.
Emerging issues such as the co-benefits
from short-lived climate forcers (i.e. black carbon and tropospheric ozone) may also be featured in the
showcase. IGES, currently serving as the secretariat for the Asian Co-benefits Partnership, could help support
such an initiative.
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Institute for Global Environmental Strategies (IGES)
Climate Change Group/Market Mechanism Group
2108-11 Kamiyamaguchi, Hayama, Kanagawa 240-0115, Japan
Telephone: +81-(0)46-855-3700 Fax: +81-(0)46-855-3709
Email: cc-info@iges.or.jp; cdm-info@iges.or.jp
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